Justia Washington Supreme Court Opinion Summaries

Sixteen-year-old Tyler Watkins was charged with first degree burglary as an adult. The former RCW 13.04.030(1) (2009) provided that juvenile courts had to automatically decline jurisdiction over 16- and 17-year-olds charged with certain offenses. Watkins argued his due process rights were violated because the automatic decline component of the statute applied without him first having a hearing on whether the juvenile court should have retained jurisdiction. The Washington Supreme Court held the automatic decline did not violate due process because juveniles did not have a constitutional right to be tried in juvenile court. View "Washington v. Watkins" on Justia Law

This case addressed the adequacy of the parole remedy available under RCW 9.94A.730, the Miller "fix" statute. Jai'Mar Scott was convicted by a jury in 1990 of first degree premeditated murder for killing his neighbor, a 78-year-old-woman who suffered from Alzheimer's disease. Scott was 17 years old when he committed the murder. The juvenile court declined jurisdiction, and Scott was tried, convicted, and sentenced as an adult. At sentencing, the parties agreed that the standard range was 240 to 320 months, with 240 months being the mandatory minimum sentence that could be imposed. The State requested an exceptional sentence above the standard range. The defense requested the low end of the standard range. The trial court sentenced Scott to an exceptional sentence of 900 months based on four independent findings: (1) that Scott's conduct constituted deliberate cruelty, (2) that his conduct was an abuse of trust, (3) that the crime involved multiple injuries, and (4) that the victim was particularly vulnerable. On direct appeal, the Court of Appeals held that the 900-month sentence imposed was not clearly excessive because the "aggravating factors are both numerous and individually and collectively egregious." The Court of Appeals also rejected Scott's assertion that his exceptional sentence was improper in light of his youth at the time of the crime. The Washington Supreme Court affirmed: consistent with the federal Supreme Court’s decision in Montgomery v. Louisiana, 136 S. Ct. 718 (2016), the Washington Court held that RCW 9.94A.730's parole provision was an adequate remedy for a Miller violation, rendering unnecessary the resentencing of a defendant who long ago received a de facto life sentence as a juvenile. View "Washington v. Scott" on Justia Law

Evan Bacon, a juvenile, pleaded guilty to second degree robbery and received a suspended disposition. The State challenged the juvenile court's authority to enter such a disposition, arguing that the Juvenile Justice Act of 1977 (JJA), chapter 13.40 RCW, does not give trial courts the statutory authority to suspend juvenile dispositions (except in specific situations that are absent here). The Court of Appeals agreed, and so did the Washington Supreme Court. The Court therefore affirmed, holding that juvenile court judges lack statutory authority to suspend JJA dispositions, even manifest injustice JJA dispositions, unless the disposition fits under one of the specifically listed exemptions in RCW 13.40.160(10). View "Washington v. Bacon" on Justia Law

Brian Buckman pleaded guilty to second degree rape of a child. After sentencing, Buckman learned that he had been misinformed of the sentencing range that applied to him. Based on this misinformation, Buckman sought to withdraw his plea as involuntary. Because Buckman's motion to withdraw was a collateral attack on his judgment and sentence, he had to show that his plea was involuntary, and actual and substantial prejudice resulting from that error. The Washington Supreme Court concluded Buckman's plea was involuntary because he was misinformed that he might be sentenced to life in prison despite the fact that the statute provided that a sentence of life in prison could not apply to a 17-year-old (Buckman's age at the time of the offense). But the Court also held he was not entitled to withdraw his plea because he failed to show that the misinformation provided at the time of his plea caused him actual and substantial prejudice. As a result, the Supreme Court denied the motion to withdraw and remanded for resentencing only. View "Washington v. Buckman" on Justia Law

As a juvenile homicide offender facing a de facto life-without-parole sentence, petitioner Joel Rodriguez Ramos was entitled to a "Miller" hearing, just as a juvenile homicide offender facing a literal life-without-parole sentence would be. Based on the record presented, the Supreme Court found that that Ramos received a constitutionally adequate Miller hearing and he did not show that his aggregated 85-year sentence violated the Eighth Amendment. View "Washington v. Rodriguez Ramos" on Justia Law

Juvenile defendant Trey M. challenged his three convictions for felony harassment under RCW 9A.46.020. The Court of Appeals certified the issue to the Washington Supreme Court of whether the United States Supreme Court's decision in "Elonis v. United States," (135 S. Ct. 2001 (2015)) had any impact on the Washington Court's "reasonable person standard" for what constituted a "true threat" under the First Amendment to the United States Constitution. The Washington Supreme Court held that because "Elonis" expressly avoided any First Amendment analysis, it provided no basis for the Court to abandon its established First Amendment precedent. Accordingly, the Court affirmed. View "Washington v. Trey M." on Justia Law

K.H.-H., a 17-year-old male, was charged with assault with sexual motivation after he forced himself on C.R., a female acquaintance who attended the same high school. The issue this case presented on appeal involved whether a juvenile disposition condition requiring K.H.-H. to write an apology letter to the victim violated his constitutional free speech rights. After review, the Supreme Court held that it did not. View "Washington v K. H.-H." on Justia Law

This case began as a call for police assistance to E.J.J. 's house to help with his intoxicated, out-of-control sister, R.J. (a juvenile at the time). The police responded and began their intervention by escorting R.J. out of the house 10 to 15 feet away from the front door, where the officers attempted to calm her down. E.J.J. grew concerned when he saw an officer reach for what he perceived to be a nightstick. E.J.J. exited the house and stood on the porch, telling the officers that R.J. was his sister and that they should not use the nightstick. The officers advised him that they were in the middle of their investigation and instructed him multiple times to leave the scene and return to the house. Initially, E.J.J. did not comply. When he did return to the home, he stood in an open doorway and continued his verbal interaction with the officers. The officers directed E.J.J. multiple times to close the solid wood door and to withdraw further into the home, but E.J.J. refused, stating that he wanted to make sure that R.J. was not harmed. E.J.J. continued to stand behind a closed wrought iron door. Multiple times, an officer reached into the home to close the solid door. E.J.J. would immediately reopen it. At this point, E.J.J. was irate, yelling profanities and calling the officers abusive names. An officer warned E.J.J. that he could be arrested for obstruction. After E.J.J. continued to reopen the solid door, an officer put him under arrest for obstruction of a law enforcement officer. E.J.J. challenged the obstruction statute as unconstitutional as applied to his behavior. "While E.J.J. 's words may have been disrespectful, discourteous, and annoying, they are nonetheless constitutionally protected." The Supreme Court reversed the conviction and dismissed the case. View "Washington v. E.J.J." on Justia Law

In January 2008, S.J.C. pleaded guilty to two counts of fourth degree assault with sexual motivation for offenses he committed at age 13. At S.J.C.'s disposition hearing, the juvenile court ordered two years of community supervision and imposed other conditions such as regular school attendance, sexual deviancy treatment, and payment of a victim penalty assessment. After completing all of his conditions, in December 2011, S.J.C. moved to vacate his adjudication and seal his juvenile record under former RCW 13.50.050. The issue this case presented for the Supreme Court's review centered on whether article I, section 10 of the Washington Constitution required the court to apply the "Ishikawa" factors when a former juvenile offender has satisfied the statutory requirements of former RCW 13.50.050 (2011) to seal his or her juvenile court record. "Based on experience and logic," the Court affirmed the juvenile court's holding that it did not. Because it was undisputed that S.J.C. met all the statutory requirements, the Court affirmed the juvenile court's order sealing his juvenile court record. View "Washington v. S.J.C." on Justia Law

The State charged Christopher Maynard in juvenile court with six counts of malicious mischief. Less than one month later, he turned 18 years old. Maynard's counsel did not move for an order to extend the court's statutory jurisdiction before Maynard turned 18. As a result, the juvenile court ruled that it had lost jurisdiction and dismissed the case without prejudice. The State then filed the case in superior court. Maynard moved to dismiss, arguing that preaccusatorial delay and ineffective assistance of counsel deprived him of the benefits of juvenile court jurisdiction, including the opportunity to accept a plea offer from the State. The trial court agreed and dismissed the case with prejudice. On appeal, the Court of Appeals reversed, holding that ineffective assistance of counsel, not preaccusatorial delay, caused the loss of jurisdiction. The court, however, determined that remand to adult trial court for a new trial was the proper remedy. The Supreme Court agreed with the Court of Appeals that Maynard received ineffective assistance of counsel which then deprived him the benefit of the opportunity to accept a plea deal. The Court vacated the Court of Appeals' order with regard to remanding of the case to the adult trial court and instead, directed the State to reoffer the plea proposal of deferred disposition consistent with the Juvenile Justice Act of 1977 (JJA), chapter 13.40 RCW. View "Washington v. Maynard" on Justia Law